Kevin G. answered 07/12/21
PhD in Biology with 20+ years teaching experience at the college level
You are at least partially right from your observations. For example, within the family Tripterygiidae, most species lack scales on their head, or have highly modified types of scales. A comparative study of 48 species showed that only 2 have "normal" scales of their head. Many fish may have large head plate like scales or have scales that are few and far between. Heck there are even some toadfish for example that lack scales all together. But I would at say that in certain families of fish this is a true statement based on your observations.
Great Question!